G.R. No. 97710 - Bondoc vs. Pineda

In the May 11, 1987 elections for Pampanga’s 4th District, Marciano M. Pineda (LDP) was proclaimed with 31,700 votes over Dr. Emigdio A. Bondoc (NP) with 28,400 votes (difference: 3,300).
Bondoc filed an electoral protest (HRET Case No. 25) before the House of Representatives Electoral Tribunal (HRET), composed of nine members: three Supreme Court Justices and six Congressmen chosen by proportional party representation.

After revision of ballots, evidence presentation, and memoranda, the tribunal reached a decision in October 1990 awarding Bondoc victory by 23 votes, later increased to 107 votes upon re-appreciation. Five members (three Justices, Congressmen Camasura and Cerilles) formed the majority.
Congressman Juanito G. Camasura, Jr. disclosed to LDP leadership that he voted for Bondoc “consistent with truth and justice,” prompting LDP expulsion resolutions on February 28 and confirmation on March 12, 1991.

On March 13, 1991, the House of Representatives plenary, notified by LDP, voted to withdraw Camasura’s nomination and rescind his election to the HRET. The HRET cancelled its March 14, 1991 promulgation of Bondoc’s favorable decision (Resolution No. 91-0018), citing lack of the required five-member concurrence.
Justices Herrera, Cruz, and Feliciano sought relief from HRET duties; the Supreme Court on March 19, 1991 directed them to resume duties, expressed concern over non-judicial intrusion, and noted terms of Tribunal members are co-extensive with legislative terms except for valid legal causes of termination.

On March 21, 1991, Bondoc filed a petition for certiorari, prohibition, and mandamus to annul the House action, enjoin any replacement of Camasura, and compel his reinstatement.
Respondents Pineda and Palacol argued the House has exclusive power to nominate and remove its HRET members to preserve party-ratio representation; the HRET’s inclusion in the petition was unnecessary, and the matter was a non-justiciable political question.

Whether the House of Representatives may withdraw and rescind its nomination of a Congressman to the HRET to prevent promulgation of a tribunal decision.
Whether the Supreme Court has jurisdiction to review and annul that legislative action.
Whether the expulsion of a HRET member for party “disloyalty” violates the independence and security of tenure guaranteed for tribunal members.